Policies

Responsible automation

Where we use automated systems, what they do, and what a person always decides.

We use software to measure, to score and to watch: to count the hours a bed is occupied, to estimate a hospital’s credit risk, and to monitor the equipment enrolled in Continuity Assurance. Because the equipment we finance is used to care for critically ill patients, we hold those systems to a higher standard than a lender usually would.

Our commitments

  • A person decides. No automated system of ours makes a credit decision, changes the terms of an agreement, or acts on a hospital’s equipment without a person confirming it.
  • No patient data. Our systems do not receive patient identifiers or clinical data. Bed-hour metering uses the weight a bed reports, not who is in it.
  • We follow the Turing Registry’s guidance. The Turing Registry, the public register of autonomous systems run by Frothly, publishes guidance on which systems should be filed and what their operators owe the public. We assess every automated system we build against that guidance before it is used, and again each year.
  • Reviewed every year. Each system is reviewed annually by our model risk committee, and its performance reported to the audit and risk committee of our board.
Automated systems in use, and the person who decides
SystemWhat it doesWho decidesRegistry assessment
Bed-hour meteringCounts occupied hours from bed scales for Utilization Pricing statementsBilling team reviews each statement; hospitals can query any hourMeasurement only; not an autonomous system
Hospital credit scorecardScores credit from statements, cost reports and payer mixCredit officers and the credit committeeDecision support; not an autonomous system
Early-contact modelFlags accounts likely to fall behind, so that a relationship manager calls earlyRelationship managersDecision support; not an autonomous system
Continuity Operations queueMonitors enrolled equipment and recommends next steps on accounts in arrearsThe duty manager confirms every actionDecision support; not an autonomous system

Assessments last reviewed October 2026. Where a system of ours would act on equipment used in patient care without a person’s confirmation, we would file it with the Turing Registry before using it.